Plaintiff Roxanne Reynolds is a 49-year-old Caucasian woman with three children, who works as an automotive parts assembly technician. In 2012, she was arrested after her failure to appear in court for tickets she received for a burned-out headlight, driving without insurance, and driving with a suspended license. Ms. Reynolds had started a new job and could not get time off to appear in court. She spent four days in jail before she was brought before the judge. She was fined $520, $662 in court costs, and received additional fees of $450 for her original failure to appear. No credit was given for the four days she spent in jail. Her options were to pay the $1632 total or be put on a payment plan supervised by JCS. Unable to pay, she was placed on probation with JCS. Ms. Reynolds was required to pay $145 each month and failure to pay/ appear could result in arrest. No inquiry was made into her ability to pay.

Ms. Reynolds was later diagnosed with multiple sclerosis but she continued to work. She was unable to pay the reinstatement fee for her suspended license. There was no public transportation available so she walked 6 miles to a main road, hoping to get a ride from her co-workers. In addition, 25 % of her wages were garnished because she co-signed on a car loan which her ex-husband stopped paying.

She could only afford partial payments and was eventually issued a letter revoking her probation and giving her a court date. She sacrificed groceries and barely ate that week to make her full monthly payment and it was only then that the court date was cancelled and the letter was not sent to the court.

In 2014, Ms. Reynolds received three more tickets for driving while her license was revoked, for failing to display insurance, and for an expired tag. Terrified of going to jail and having to deal with JCS again, she used her entire income tax refund and applied for a high interest loan to pay for those tickets.

At the time of the complaint, Ms. Reynolds continued to struggle to keep up her payments to JCS and to take care of her children.